Privacy Policy

This Privacy Policy explains how Fengming Media Solutions LLC ("Fengming", "we", "us") collects, uses, shares and protects personal information when you visit fengming.media, contact us, request a demo, or interact with our communications. It is designed to meet the requirements of the EU and UK General Data Protection Regulation ("GDPR") and of US state privacy laws, including the California Consumer Privacy Act as amended by the CPRA ("CCPA").

This policy does not cover personal data that our business customers upload to our software products. For that data, our customer is the controller and we act as its processor under our Data Processing Addendum.

1. Who is responsible for your data

• Controller: Fengming Media Solutions LLC, 30 N Gould St, Ste N #59422, Sheridan, WY 82801, USA.
• Contact for privacy matters: privacy@fengming.media
• EU representative (Art. 27 GDPR): pending appointment — the representative's details will be published here once designated.

2. Personal data we collect

a) Data you give us

• Contact and demo requests: name, email address, company, phone number (optional), area of interest, the product you are interested in and the content of your message.
• Business relationship: contact details of customer and supplier representatives, contract, billing and payment information, and correspondence.
• Communications: emails and messages you exchange with us.

b) Data collected automatically

• Technical data: IP address, browser type, device information, language, pages visited, referring page, date and time of access. Our hosting provider records this data in server logs for security and operation.
• Analytics data (only with your consent where required): information about how you use the website collected through Google Analytics, such as pages viewed, approximate location derived from the IP address, device type and interactions.
• Advertising data (only with your consent where required): identifiers and events collected through the Meta Pixel to measure the effectiveness of our advertising and to show relevant ads on Meta platforms (Facebook, Instagram).

See our Cookie Policy for the cookies and similar technologies we use.

We do not knowingly collect sensitive personal information and we ask you not to send it to us.

3. Why we use your data and on what legal basis (GDPR)

Purpose	Legal basis
Answering your enquiries and preparing demos or proposals you request	Steps at your request before entering into a contract (Art. 6(1)(b)) and our legitimate interest in responding (Art. 6(1)(f))
Providing our services and managing the contractual relationship, billing and support	Performance of a contract (Art. 6(1)(b))
Complying with tax, accounting and other legal obligations	Legal obligation (Art. 6(1)(c))
Keeping the website secure and working, preventing fraud and abuse	Legitimate interest (Art. 6(1)(f))
Website analytics with Google Analytics	Consent (Art. 6(1)(a))
Measuring and personalizing advertising with the Meta Pixel	Consent (Art. 6(1)(a))
Sending you information about our products when you are a business contact or customer	Legitimate interest (Art. 6(1)(f)) or consent where required by law. You can object at any time

Where we rely on consent, you can withdraw it at any time using Cookie settings in the footer of the website, without affecting the lawfulness of processing carried out before withdrawal.

4. Who we share your data with

We do not sell your personal information for money. We share personal data only with:

• Service providers (processors) that help us run our business, under contracts that require them to protect the data and to use it only on our instructions:
  • Hostinger — website hosting and business email.
  • Brevo — sending transactional and informational emails.
  • Google (Google Workspace) — business email, documents, calendar and collaboration tools.
  • Google (Google Analytics) — website analytics, only when you allow analytics cookies.
• Meta Platforms — when you allow marketing cookies, the Meta Pixel sends website event data to Meta. For the collection and transmission of that data, Meta and Fengming may act as joint controllers; Meta's own processing is governed by its privacy policy.
• Professional advisers (lawyers, accountants, auditors) under duties of confidentiality.
• Authorities, when required by law or to protect our rights.
• Successors, if our business is reorganized, merged or sold, subject to this policy.

5. International data transfers

Fengming Media Solutions LLC is a United States company, and some of our providers process data in the United States or other countries outside the European Economic Area (EEA) and the United Kingdom. When we transfer personal data outside the EEA or the UK, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (and the UK addendum), or on the recipient's certification under the EU-US Data Privacy Framework and its UK extension where applicable. You can request more information about these safeguards at privacy@fengming.media.

6. How long we keep your data

• Enquiries and demo requests: up to 24 months after our last contact, unless a business relationship starts.
• Customer and contract data: for the duration of the relationship and afterwards for the period required by tax, accounting and limitation laws.
• Analytics data: according to the retention settings configured in Google Analytics (up to 14 months).
• Marketing cookies: according to the durations listed in the Cookie Policy.
• Server logs: for a limited period set by our hosting provider for security purposes.

7. Your rights under the GDPR (EEA, UK and Switzerland)

You have the right to: access your personal data; rectify inaccurate data; request erasure; restrict processing; data portability; object to processing based on legitimate interests, including profiling, and to object at any time to direct marketing; and withdraw your consent at any time.

To exercise your rights, write to privacy@fengming.media. We will answer within one month, which may be extended in the cases provided by law. We may ask you to confirm your identity.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work. In Spain, this is the Agencia Española de Protección de Datos (www.aepd.es).

8. Your privacy rights in the United States

This section applies to residents of California and of other US states with comprehensive privacy laws (such as Colorado, Connecticut, Virginia, Utah, Texas, Oregon and others), to the extent those laws apply to us.

Categories of personal information collected in the last 12 months: identifiers (name, email, phone, IP address, online identifiers); commercial information (products or services requested); internet or other electronic network activity (browsing and interaction data); approximate geolocation derived from the IP address; and professional or employment-related information (company and role). We do not collect sensitive personal information as defined by the CCPA.

Sources: directly from you, automatically from your device, and from our service providers.

Business purposes: the purposes described in section 3, including responding to enquiries, providing our services, security, analytics and advertising.

"Sale" and "sharing": we do not sell personal information for money. However, the use of advertising technologies such as the Meta Pixel may be considered a "sale" or "sharing" of personal information for cross-context behavioral advertising under some US laws. You can opt out at any time by clicking Your Privacy Choices in the footer of the website. We also honor the Global Privacy Control (GPC) signal sent by your browser as a valid opt-out request. We do not knowingly sell or share the personal information of consumers under 16 years of age.

Your rights: depending on your state of residence, you may have the right to know what personal information we have collected about you, to access it and obtain a portable copy, to correct it, to delete it, to opt out of the sale or sharing of personal information and of targeted advertising, and not to be discriminated against for exercising these rights.

How to exercise your rights: email privacy@fengming.media. We will verify your request using the information we hold about you and respond within 45 days, which may be extended once by an additional 45 days when reasonably necessary. You may use an authorized agent; we may require proof of the agent's authorization and verification of your identity.

Appeals: if we decline your request, you may appeal by replying to our decision or writing to privacy@fengming.media with the subject "Privacy appeal". We will respond within the time required by your state's law. If your appeal is denied, you may contact your state Attorney General.

9. Children

Our website and services are intended for businesses and professionals and are not directed to children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

10. Security

We apply technical and organizational measures appropriate to the risk, including encrypted connections (HTTPS), access controls and providers with recognized security practices. No system is completely secure, so we cannot guarantee absolute security.

11. Changes to this policy

We may update this Privacy Policy from time to time. We will publish the new version on this page with its update date and, if the changes are significant, we will inform you by appropriate means.

12. Contact

For any question about this policy or your personal data, contact us at privacy@fengming.media or by mail at Fengming Media Solutions LLC, 30 N Gould St, Ste N #59422, Sheridan, WY 82801, USA.